kolum and BearingPoint came together Tuesday, 17.03.2026 to discuss what the start of the definitive CBAM period in 2026 means for importers, operational teams, and procurement functions. With embedded emissions now driving financial exposure from 1 January 2026, the session focused on emissions data governance, verification obligations, and practical preparation for the first purchase and surrender cycle in 2027.

Business as usual is no longer an option

Key insights included:

  • Compliance now requires installation‑level, evidence‑supported actual emissions
  • Companies must operate with structured, auditable, and repeatable data collection processes.
  • Suppliers must deliver verifiable upstream data - incomplete datasets will push companies toward financially punitive default values.
  • The shift into 2026 means spreadsheet‑based, reactive workflows can no longer sustain CBAM requirements.

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Verification of 2026 emissions

Participants received clarity on what verification means under the CBAM rules:

  • Only verified actual emissions can be used in the 2027 declaration.
  • Third‑country installations must provide complete evidence packages covering measurements, calculations, calibration, precursors, and methodologies.
  • Missing or unverifiable data will automatically force the use of default values, increasing cost exposure.
  • Verification must be treated as a 2026 operational task, not as a later clean‑up activity.

Q&A highlights

Pre‑verification provides a clear advantage. Although not required by legislation, a pre‑verification (or internal dry run) is strongly recommended.
It helps organisations:

  • Detect inconsistencies early
  • Expose gaps in supplier data
  • Validate alignment with CBAM calculation rules
  • Reduce the risk of default value application during the official verification cycle

This positions companies for a smoother verification of their 2026 emissions.

Certificate price simulations should not rely on a single assumption

When modelling financial exposure, using a certain value can be a helpful reference - but should not be the only scenario.

Key points:

  • The 2026 CBAM certificate price will reflect the quarterly average EU ETS auction price
  • Companies should simulate multiple price points (e.g., €60 / €80 / €100 / €120 per tonne).
  • This supports budgeting, supplier negotiations, and internal cost allocation in a more resilient way.

The takeaway: financial planning must allow for price volatility, not a single anchor.

Interactive Poll Results

Participants were asked about their readiness for the first verification cycle in 2027 (covering 2026 emissions):

Response Share

a. We are ready: data and evidence trail are in good shape

 33%

b. We’ve started preparing, but there are still gaps

 33%

c. We’re not ready: significant challenges encountered

 33%

Conclusion

Both kolum and BearingPoint highlighted that 2026 is the decisive year for operationalising CBAM. Strong data governance, reliable supplier engagement, and readiness for verification are the cornerstones of avoiding unnecessary financial exposure in 2027.

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